At a Chatham County jail, contractor Corizon repeatedly referred inmate Danielle Burton for mental-health care, including an urgent referral, but she had not seen a psychiatrist by May 27, 2014. During an escort for lice treatment, Burton resisted officers’ attempt to restrain her and injured detention officer Wendy Smoot-Lee, who later required surgery; Burton said she would not have attacked if medicated. Smoot-Lee sued Corizon for failing to treat Burton, and the trial court granted summary judgment. On appeal, she argued Corizon controlled Burton because she could not leave jail and the provider could recommend involuntary confinement. The Court of Appeals of Georgia affirmed. Under Bradley Center, a provider’s third-party duty requires control over the patient and knowledge, actual or constructive, that the patient was likely to harm others. The jail agreement assigned custody and security to the sheriff’s office, which restrained Burton; Corizon provided medical care and referrals but lacked authority over her liberty. The court also rejected a duty based on Corizon’s alleged ability to recommend involuntary commitment: for third-party claims, the control requirement turns on actual control or authority to restrain, not whether commitment might have been warranted. Summary judgment for Corizon was affirmed.